Is there a transition or sell-off period?

As things stand, the implementing act provides for no general transition or sell-off period. Packaging carrying impermissible claims should therefore be changed in good time, because prepress, approval and selling off existing stock all need lead time.

The transposition came as an amendment to the German Unfair Competition Act, promulgated in the Federal Law Gazette of 19 February 2026; the rules apply from 27 September 2026. Anyone planning print production should allow several months: artwork change, internal sign-off, new print run and sell-off of remaining stock happen one after another, not in parallel.

What applies to old stock

The rules expressly also cover packaging manufactured, ordered, distributed or placed on the shelf before the application date. In June 2026 the national authorities in the European Consumer Protection Cooperation Network (CPC) published a common understanding on this: enforcement may be phased where old stock gives rise to genuine and specific transitional difficulties, practical constraints such as packaging cycles and orders already placed are taken into account, and in justified cases compliance comes before sanctions. What is expected in return are all reasonable and proportionate efforts, evidenced by records showing what was done and when. That is not a general sell-off period, and the paper is not binding either.